On May 3, 2022, the California Court of Appeal issued its decision in Shaw v. Superior Court, 78 Cal. App. 5th 245, 2022 WL 1400806 (2022), holding that in cases where two or more pending Private Attorneys General Act (PAGA) actions overlap, the exclusive concurrent jurisdiction rule may justify staying the later-filed cases.
As courts have observed, 'nothing in the PAGA statutory scheme forecloses separate but similar actions by different employees against the same employer.' Julian v. Glenair, Inc., 17 Cal. App. 5th 853, 866 (2017). As a result, it is not uncommon for a PAGA action to duplicate claims in a preexisting...